NOTICE OF DISCIPLINARY ACTION

NON-MEMBER:

Monick LLC

CBOT RULE VIOLATIONS:

Rule 432. General Offenses (in part)

It shall be an offense:

W. for any party to fail to diligently supervise its employees and agents in the conduct of their business relating to the Exchange.

Rule 575. Disruptive Practices Prohibited (in part)

D. No person shall enter or cause to be entered an actionable or non-actionable message(s) with intent to disrupt, or with reckless disregard for the adverse impact on, the orderly conduct of trading or the fair execution of transactions.

FINDINGS:

Pursuant to an offer of settlement in which Monick LLC neither admitted nor denied the rule violations or factual findings upon which the penalty is based, on September 30, 2022, a Panel of the Chicago Board of Trade (“CBOT”) Business Conduct Committee (“Panel”) found that on multiple occasions between February 28, 2020, and April 6, 2020, an automated trading system (“ATS”) operated by Monick entered crossed-market orders in Soybean, Soybean Meal, Corn, and Chicago SRW Wheat futures during the pre-open session due to a programming error and adversely impacted the Indicative Opening Price (“IOP”). Market Regulation contacted Monick on multiple occasions after the initial incident regarding its errant messaging activity. Monick was unable to properly correct the programming error and on multiple occasions between April 6, 2020, and November 26, 2021, the ATS again entered crossed-market orders during the pre-open sessions in Soybean, Soybean Meal, Corn, and Chicago SRW Wheat futures and adversely impacted the IOP. The Panel found that Monick, in failing to implement procedures to prevent the ATS from continually entering and canceling messages during the preopen period, failed to properly supervise the ATS. The Panel concluded that Monick thereby violated CBOT Rules 432.W. and 575.D.

PENALTY:

In accordance with the settlement offer, the Panel ordered Monick to pay a $50,000 fine in connection with this case and companion case CME 20-1337-BC ($15,000 of which is allocated to CBOT).